Epstein Secrets

w York, New York 10004 BY: LARRY FALLEK, ESQ. CUOMO, LLC. Attorney for Defendant 116 EAST 65TH STREET, LLC. 200 Old Country Road, Suite 2 South Mineola, New York 11501 BY: MATTHEW CUOMO, ESQ. FILE NO.: AIGPRIV 17007 DEITZ Court Reporting... A Lexitas Company 800-676-0166 SDNY_GM_00323956 EFTA_0

14:21,23 29:3 notes (1) Old (1) Paneth (1) mine (1) neighbor (2) 65:8 2:10 57:24 25:15 35:19,25 notice (2) one-family (1) paperwork (6) Mineola (1) neighbor's (1) 43:7 61:3 67:10 12:23,24 26:3 2:10 35:8 number (3) operate (1) 51:10 57:17 misundersto... never (12) 18:17 55:9,9 75:8

Were there any contracting employees back in 2015 for Terramar Project, Inc.? A. There were, yes. Q. Who were they? A. One. I believe it was Robert Foos. Q. In what position did he hold? A. I think his official title was Director Of Development. Q. Does the additional data sheet indicate that

w York, New York 10004 BY: LARRY FALLEN, ESQ. CUOMO, LLC. Attorney for Defendant 116 EAST 65TH STREET, LLC. 200 Old Country Road, Suite 2 South Mineola, New York 11501 BY: MATTHEW CUOMO, ESQ. FILE NO.: AIGPRIV 17007 DEITZ Court Reporting... A Lexitas Company MOONS-0166 SDNY_GNA_02775802 EFTA_00

14:21,23 29:3 notes (1) Old (1) Paneth (1) mine (1) neighbor (2) 65:8 2:10 57:24 25:15 35:19,25 notice (2) one-family (1) paperwork (6) Mineola (1) neighbor's (1) 43:7 61:3 67:10 12:23,24 26:3 2:10 35:8 number (3) operate (1) 51:10 57:17 misundersto... never (12) 18:17 55:9,9 75:8

Were there any contracting employees back in 2015 for Terramar Project, Inc.? A. There were, yes. Q. Who were they? A. One. I believe it was Robert Foos. Q. In what position did he hold? A. I think his official title was Director Of Development. Q. DOOS the additional data sheet_ indicate that

S: THE LAW OFFICE OF JOSEPH FALLEK Attorney for Plaintiffs New York, New York 10004 BY: LARRY FALLEK, ESQ. CUOMO, LLC. Attorney for Defendant Mineola, New York 11501 BY: MATTHEW CUOMO, ESQ. FILE NO.: AIGPRIV 17007 EFTA00065871 WILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pf. NYSCEF DOC. NC.

contracting employees back 15 in 2015 for Terramar Project, Inc.? 16 A. There were, yes. 17 Q. Who were they? 18 A. One. I believe it was Robert Foos. 19 Q. In what position did he hold? 20 A. I think his official title was Director of 21 Development. 22 Q. Does the additional data sheet

ion) Note the File # has an AIG PRIV prefix (this has to mean that AIG is her insurance carrier on this case). CUOMO, LLC. Attorney for Defendant Mineola, New York 11501 BY: MATTHEW CUOMO, ESQ. FILE NO.: AIGFRIV 17007 EFTA00011365 --- PAGE BREAK --- SUPREME COURT OF THE STATE OF NEW YORK COUNTY

ve one person who did work for Terramar Project. They were always ()trait*, beCadae they would never come to work. They would be remote. Page 55: Robert Foos was a contracted employee for Terramar (Director of Development) Who paid him? EFTA00011377 --- PAGE BREAK --- 14 15 16 17 16 21 22 21 7